Testimony of Steven Emerson
House Committee on Financial Services Subcommittee on Oversight and Investigations
"PATRIOT Act Oversight: Investigating Patterns of Terrorist Fundraising“
Fund-Raising Methods and Procedures for International
February 12, 2002
The Investigative Project
A Biographical Sketch
5505 Connecticut Avenue, NW, #341, Washington DC 20015-2601
Phone: (202) 363-8602 Fax: (202) 966-5191
Steven Emerson is an internationally recognized expert on terrorism and national security, a
correspondent, and an author who also serves as the Executive Director of The Investigative Project.
His current book, American Jihad: The Terrorists Living Among Us, published by The Free Press,
details the rise of the militant Islamic infrastructure in the United States and provides the most
comprehensive account of the major fundamentalist Islamic cells on American soil to date.
Mr. Emerson started The Investigative Project in late 1995 following the broadcast of his
documentary film, "Jihad in America," on public television. The film exposed video of clandestine
operations of militant Islamic terrorist groups on American soil. For the film, Mr. Emerson received
numerous awards including the George Polk Award for best television documentary, one of the most
prestigious awards in journalism. He also received the top prize from the Investigative Reporters and
Editors Organization (IRE) for best investigative report in both print and television for the
documentary. The award from the IRE was the fourth such award he had received from that group.
Since 1996, Mr. Emerson has testified more than a dozen times before Congress on such
topics as the terrorist infrastructure in the US, Palestinian violations of the Oslo accords, the
protection of America's national infrastructure, and the threat of Islamic fundamentalism against
the United States and the West. He regularly appears in the Wall Street Journal op-ed page as
well as numerous other publications, and gives frequent interviews to television networks
throughout the United States and abroad.
Mr. Emerson first worked for the U.S. Senate Foreign Relations Committee starting in
1977. He then became a freelance writer in 1982, writing primarily for the New Republic. Mr.
Emerson is the author of four books. He published his first book in 1985, The American House of
Saud: The Secret Petrodollar Connection. Mr. Emerson joined U.S. News and World Report
magazine in 1986 as the national security correspondent where he published two more books:
Secret Warriors and The Fall of Pan Am 103: Inside the Lockerbie Investigation. In 1990, Mr.
Emerson joined CNN as a special investigative correspondent. In 1993, Mr. Emerson left CNN
to begin work on his PBS "Jihad in America" documentary that aired at the end of 1994.
President George Bush stated on September 24, 2001, —Money is the life- blood of
terrorist operations. Today, we're asking the world to stop payment.“ Since then, the US
government has engaged in a full-court press designed to freeze, seize, interrupt, slow down and
otherwise interdict the flow of funds to terrorists. To a certain extent, however, government
agencies were forced to act without having first developed the critical intelligence base on
terrorist fundraising that would ordinarily would have preceded prior to government action. But
these were not ordinary times–and it became imperative that the flow of funds available to
terrorists be shut down immediately. Government agencies and law enforcement rose to the
occasion and performed brilliantly. The American public owes a great deal of gratitude to the
thousands of government agents who have worked tirelessly on tracking down terrorist assets
around the globe.
But with the benefit of hindsight and the opportunity to distill investigative intelligence,
we can now step back and examine the primary routes through which terrorists have raised or
laundered monies. . The manner in which terrorists have raised money for their horrific
operations has ranged from a variety of sources including, but not limited to, the use of charitable
organizations, corporate —front“ entities, financial institutions, and Internet-based funding. The
1998 bombing of the U.S. Embassies in Kenya and Tanzania provided a prime example of how
these means of fund-raising were all utilized.
This testimony will probe into the means of fundraising by such organizations as al-
Qaeda, Hamas, and Hizballah. The significance of this broad sampling of organizations is to
show that each of these terrorist organizations utilize the same types of methods to fund their
A fundamental exploitation that Islamic fundamentalists have been able to avail
themselves of so efficiently and thoroughly is through a charity or relief organization. For most
of the world, charities represent all that is good about mankind–helping others in need, bringing
people together, and correcting the wrongs of the world. But for the terrorist, charities represent
a perfect cover for collecting large amounts of money and arms to be used for terrorist
The general public often cringes at the thought that charities designed for benevolent
purposes can be used to support terrorism. Often, First Amendment concerns are raised
regarding a charity‘s freedom of speech and freedom of association and the overreaching of
federal law enforcement against legitimate charities. Therefore, scrutiny of these charities by
federal law enforcement authorities has sometimes been met with media criticism based on such
concepts as —ethnic profiling“ and discrimination.
Unfortunately, terrorists do in fact utilize charitable organizations within the United
States to accomplish their funding purposes. Furthermore, because charities face far less
scrutiny from the IRS than other for-profit corporations and individuals, occasionally, these
same charities that engage in terrorist pursuits have succeeded in receiving financial assistance
from government-sponsored grant programs such as the U.S. Agency for International
Development (USAID). For example, the Holy Land Foundation for Relief and Development
(HLFRD), whose assets were ordered frozen for funding the Hamas terrorist organization, was
approved by USAID to receive supplemental funding.1 Disturbingly , when charities like
HLFRD are funding terrorism, they are doing so at the expense of the American taxpayer, while
undermining the fundamental values that the United States represents.
a. Al-Qaeda‘s Abuse of Charities
Al-Qaeda has availed itself of the freedoms inherent within the American political spectrum
in order to reap financial benefits. The following examples show how this has been
1. The International Islamic Relief Organization (IIRO)
Foremost among charities tied to Osama Bin Laden and al-Qaeda, as well as other
terrorist organizations such as Hamas, is the International Islamic Relief Organization (IIRO).
The IIRO, which has many branches around the world, was established in 1978 and is
headquartered in Jeddah, Saudi Arabia.2 The current Secretary-General of the IIRO is Adnan
Khalil Basha. The IIRO is considered to be the —operating arm“3 of the Muslim World League
(MWL), and, according to Dr. Ahmed Mohammed Ali, Secretary-General of the MWL, it
provides —humanitarian assistance“ through the IIRO.4
There is documentary evidence of IIRO‘s solid ties to serving as a conduit for terrorism.
Most recently, a man arrested in Canada who worked for the IIRO was found to have numerous
ties to al-Qaeda and Osama Bin Laden. Mahmoud Jaballah, working as a principal in an Islamic
school in Canada, was arrested in 1999 for allegedly belonging to Al Jihad, an organization
thought to work closely with al-Qaeda and led by one of al-Qaeda‘s top lieutenants, Ayman Al-
Zawahiri. Jaballah was released almost a year later due to a lack of evidence against him, but
was rearrested in August 2001 when the Canadian Security Intelligence Service (CSIS)
uncovered new information solidifying Jaballah‘s connections to al-Qaeda.5
During his deportation hearing, Jaballah stated he worked for the IIRO in Peshawar,
Pakistan, in the capacity of —teaching orphans.“6 Despite these claims, a diagram introduced by
the Canadian government at the trial tells a different story. The diagram illustrates the
connections between various individuals and organizations all linked to Al Jihad. An arrow
beginning at IIRO and pointing directly to Al Jihad has the words —Secretly funds terrorism“
superimposed upon the arrow. [SEE EXHIBIT] It is the Canadian government‘s contention,
Mike Allen and Steven Mufson. —U.S. Seizes Assets of 3 Islamic Groups; U.S. Charity Among Institutions
Accused Of Funding Hamas.“ The Washington Post. December 5, 2001.
—IIRO œ Welcome.“ http://www.arab.net/iiro
State Department Cable. Document Number: 1994MANILA19999. November 1994. Page 261.
Ahmed, Iftikhar. —Counter anti-Islam propaganda, says MWL sec-general.“ Moneyclips. May 6, 1995.
—Federal judge to interview CSIS agents to determine Egyptian refugee‘s fate.“ Canadian Press Newswire.
January 8, 2002.
Deportation Hearing of Mahmoud Jaballah, Volume 2, Page 23
then, that IIRO funds terrorism clandestinely. Jaballah was eventually —processed for
deportation as a threat to national security.“7
A CSIS operative, named in the trial only as —Mike“ to preserve his anonymity,
elucidated how a relief organization could operate as a means to actively support terrorism:
[M]ost members of Al Jihad, as cover for their operations, usually employ
themselves with relief organization as teachers or as aid workers. Just to give you
a few examples, Mercy International was one of the organizations that was used
to support the network of Al Jihad when it was conducting its operation against
American embassies in East Africa when they were blown up. An organization
by the name of Human Concern International, one of whose employees is a man
by the name of Ahmed Said Khadr, used the network of Human Concern
International to facilitate the attack on the Egyptian embassy in Islamabad in
The IIRO‘s road to terrorism might even lead to September 11, 2001. Fayez Ahmed
Alshehri, one of the hijackers on United Airlines Flight 175 which crashed into the southern
tower of the World Trade Center, told his father he was going to go work for the IIRO and never
saw his family again.9 Whether IIRO was the gateway for this hijacker‘s entry into terrorism is
unclear, but it necessitates a further investigation.
IIRO branches provide more than a base for recruitment for terrorists. They also
provide material support, instructions, and funding. On January 7, 1999, according to Karnal
Singh, a deputy inspector-general of police in India, the U.S. consulates in Madras and Calcutta
were targeted by a Bangladeshi national, Sayed Abu Nasir, on orders from among others, Sheikh
Al Gamdin, President of the IIRO, Asia.10 After September 11, 2001 Pakistan deported 89 Arab
aid workers in order to cut support for Bin Laden and al-Qaeda. Among the organizations that
employed these workers was the IIRO.11
In the Philippines, the IIRO office in Zamboanga City is the coordinating center for
secessionist Islamic militants in the southern region of the country where Muslims are the
majority.12 IIRO‘s Zamboanga City office, which was established some time in the early 1990s,
was under the direct control of Mohammad Jamal Khalifa, the brother-in-law of Osama Bin
In April 1994, Khalifa was indicted by Jordanian authorities for being involved in the
bombing of a cinema in Jordan. Later that year, on December 1, Khalifa entered the United
Stewart Bell. —Canadian and Muslim, but are they terrorists?“ The National Post. February 9, 2002.
Trial of Mahmoud Jaballah, December 17, 2001, Page 330.
Ba-Isa, Molouk Y. & Saud Al-Towaim. —Another Saudi ' hijacker' turns up in Tunis.“ Middle East Newsfile.
September 18, 2001.
Cecelia Dugger. —Anti-U.S. Plot in India Is Foiled.“ International Herald Tribune. January 21, 1999.
—Pakistan Deporting 89 Arab Aid Workers.“ The Associated Press. October 6, 2001.
Christine Herrera. —BIN LADEN FUNDS ABU SAYYAF THROUGH MUSLIM RELIEF GROUP.“ Philippine
Daily Inquirer. August 9, 2000.
Peter Chaulk. —TERRORISM - Bin Laden's Asian network.“ Jane‘s Intelligence Review. December 1, 1998.
States on a visa he had applied for earlier. Two weeks later, Khalifa was arrested and extradited
to Jordan where he was subsequently acquitted of charges against him.
The State Department was gathering information pursuant to Khalifa‘s application for a
visa and entry into the United States. In 1994, a cable from the American Embassy in Manila,
Philippines, to the Secretary of State summarized the findings of the local media:
A Saudi Arabian-based relief agency operating in Manila had been coordinating
with and helping Muslim Secessionist factions in Mindanao and the ASG [Abu
Sayyaf Group]. The head of the Agenqr((-#“M- [sic] (Islamic Relief
Organization (IIRO)), is identified as a Saudi named Muhamad Jammal
Through Khalifa and the IIRO, Bin Laden ensured an instrumental role in the militant
Another cable from 1994, from the Secretary of State to American Embassy in Khartoum further
solidified Khalifa‘s role as a terrorist:
FYI, Osama Bin Laden‘s brother-in-law, Muhammad Jamal Khalifah [sic], was
arrested in California on 12/16. REFTEL refers to Khalifa as a —known financier
of terrorist operations“ and an officer of an Islamic NGO in the Philippines that is
a known Hamas front. He is under indictment in Jordan in connection with a
series of cinema bombings earlier this year.16
According to reliable reports, western intelligence sources have traced IIRO money
transfers to bank accounts in London, England and Amman, Jordan; which is then channeled
through front groups to Palestinian Hamas-backed organizations in the West Bank and Gaza
Strip.17 Mohammed al-Zawahiri, brother of Dr. Ayman al-Zawahiri who is one of Osama Bin
Laden‘s top lieutenants, worked all over the world for the IIRO.18 Mohammed al-Zawahiri was
sentenced to death in absentia in Egypt and is believed to lead the Jihad Organization‘s military
As part of its international presence, the IIRO has a distinct but suspiciously
compartmented presence in the United States. The organization epitomizes how current record
keeping can make following the money flow of relief organizations and charities extremely
difficult. By understanding how IIRO functions in the United States, we can better understand
how to improve upon our current system of maintaining public records for these charities.
Armed with more accurate records, a more effective, tight tourniquet can be made to stop the
money flow supporting terrorism.
State Department Cable. Document Number: 1994MANILA19999. November 1994. Page 261.
Peter Chaulk. —TERRORISM - Bin Laden's Asian network.“ Jane‘s Intelligence Review. December 1, 1998.
State Department Cable. Document Number: 1994STATE335575. December 1994. Page 360.
Richard Chesnoff and Robin Knight. —A helping hand from Saudi Arabia.“ U.S. News and World Report. July 8,
—Official sources deny reports on UAE's extradition of Islamist.“ Al-Hayat, London. June 7, 2000.
Within the United States, the IIRO works through two other differently-named
organizations, the International Relief Organization (IRO) and the Success Foundation.19 All
three organizations are in reality one and the same. According to corporate filings with the
Virginia Secretary of State, the IRO is —doing business as“ the —International Islamic Relief
Created shortly before the U.S. Embassy bombings in East Africa in 1998, the Success
Foundation was a recipient of $15,000 from the IRO (according to IRO‘s Tax Form 990 filed
with the IRS in 1998) that was earmarked for —educational expenses.“ Line item 80 in Success
Foundation‘s Tax Form 990 for 2000 filed with the IRS lists the —International Relief
Organization“ as an organization to which it is related, though this information is lacking in
IRO‘s parallel form.
. With three incorporated institutions all co-existing together in the United States, this
relief organization has the infrastructure ready to quickly shift funding from one to the other, as
they have in the past. Thus, the money trail is extremely complicated and constantly in flux.
IIRO does not limit this shifting of money to its trio of American NGOs. In 1996 through 1998,
on the IRO‘s Income Tax Form 990, the relief organization listed among its itemized educational
expenses a donation to the Holy Land Foundation for Relief and Development (HLFRD). In
1996 alone, IRO donated $21,980 to HLFRD. On December 4, 2001, the Holy Land
Foundation‘s assets were ordered frozen, and it was branded a Specially Designated Global
Terrorist [SDGT] Entity for funding the Hamas terrorist organization.
After the devastating attacks on September 11, 2001, intelligence scrambled to
understand how the hijackers financed their operation. From basic issues such as housing,
clothing, food, and transportation, to the logistics of the operation, including purchasing plane
tickets, obtaining false identifications, and combat training, al-Qaeda necessarily provided
funding. When President Bush‘s first Executive Order blocking terrorist property was issued on
September 24, 2001, most of the world was shocked to note that charities were among the
In its corporate record registered with the Virginia Secretary of State, IRO lists its office as:
P.O. BOX 8125
Falls Church, VA 22041
On the Success Foundation‘s Income Tax Form 2758 for calendar year 1999, used for an application to extend time
to file information with the IRS, the organization lists exact same address. Furthermore, IRO lists its phone number
on its 1999 Income Tax Form 990 as (703) 820-7199. Success Foundation lists the same number on its 1999
Income Tax Form 990, despite bearing a different address.
The leadership is closely shared between the IRO and Success Foundation. In 1992, IRO on its Income Tax Form
990 listed Khaled Nouri as its Treasurer. In 1999 and 2000, IRO on its Income Tax Form 990 listed Mohamed
Omeish as its President and Secretary. In 1999, Success Foundation listed on its Income Tax Form 990 that
Mohamed Omeish was its Director and President and also listed Khaled Nouri as another Director. Success
Foundation listed in both its 1999 and 2000 Tax Form 990 Mohamed Omeish as its President, Abdurahman
Alamoudi as its Secretary and Khaled Nouri as its Treasurer. Alamoudi‘s signature appears on Success
Foundation‘s Income Tax Form 2758 requesting an extension of time to file the organization‘s income tax return.
Alamoudi‘s position is listed as Chairman.
Virginia Secretary of State, Corporate Record., Corporate Number 378687
organizations whose assets were frozen and designated SDGTs. To fund this attack, al-Qaeda
had to collect and disperse money, and they did so through various charities. Charities played a
key role in the September 11th attacks, and they will continue to raise money for terrorist
activities unless forceful action is taken with both care and alacrity.
2. Charities Associated with the September 11, 2001 Terrorist Attacks
The next section will discuss two charities that have been primary in the post-September
11, 2001, investigation into the funding of al-Qaeda operations. The Wafa Humanitarian
Organization was included as the first charity on President Bush‘s initial list of organizations and
individuals designated as Specially Designated Global Terrorist Entities [SDGT] that was issued
on September 24, 2001. This initial list was comprised of individuals and organizations alleged
to have been complicit in the terrorist attacks of September 11, 2001. The Rabita Trust for the
Rehabilitation of Stranded Pakistanis was designated as a SDGT on October 12, 2001.
The Wafa Humanitarian Organization
Funded from Saudi Arabia21, the Wafa Humanitarian Organization was the first charity
tied to terrorism to have its assets frozen post-September 11. One of the highest ranking officials
captured in December in Afghanistan is Abdul Aziz, a Saudi who is also with the Wafa
Humanitarian Organization.22 As reported in an Afghan Taliban radio report in June 2001, the
Taliban‘s Minister of Public Works, Mowlawi Ahmadollah Moti, —met the head of the Wafa
charity organization, esteemed Sheikh Abo Abdol Aziz Naqi“ where —both sides discussed
matters of mutual interest and repair of highways inside the country.“23
Wafa also worked closely with Pakistani nuclear scientists. The FBI contends that Wafa
coordinated activities with Ummah Tameer-e-Nau,24 a charity and organization closely tied to al-
Qaeda. Ummah Tameer-e-Nau‘s assets were frozen on December 20, 2001, by the U.S.
Treasury Department and designated a SDGT. Ummah Tameer-e-Nau was founded by Sultan
Bashir-ud-Din Mehmood, one of the top Pakistani nuclear scientists. Mehmood worked for
more than 30 years to develop Pakistan‘s nuclear capabilities, and ultimately, succeeded in
building a nuclear bomb in 1998.25 Along with Mehmood, Abdul Majeed served on Pakistan‘s
Atomic Energy Commission until the two retired in 1999.
Ummah Tameer-e-Nau epitomizes an organization operating as a charity to remain
clandestine. The charity was allowed to operated freely in Afghanistan, a privilege bestowed
only to a small minority of NGOs. The Taliban went so far as to permit Ummah Tameer-e-Nau
to make business deals on the Taliban‘s behalf.26 Given Ummah Tameer-e-Nau‘s status as a
—Saudi Arabia announces first freeze of terrorist bank accounts since Sept. 11.“ The Associated Press. February
James Risen. —A NATION CHALLENGED: THE MOST WANTED; Taliban Chiefs Prove Elusive, Americans
Say.“ The New York Times. December 20, 2001.
—Afghan Taleban to repair highways in south and east.“ Radio Voice of Shari'ah, Kabul, in Pashto. June 10,
—Nuclear scientists picked by agencies.“ Islamabad Pakistan Observer. October 25, 2001.
Peter Popham. —Campaign Against Terrorism.“ The Independent (London). October 31, 2001.
charity, the world community ignored the group‘s involvement in Afghanistan and the Taliban.
Ironically, while the world gave its tacit approval to Ummah Tameer-e-Nau, secret meetings
were being held between Osama Bin Laden and the organization. Shortly after the September 11
attacks, Mehmood and Majeed were taken into custody by the Pakistani government for these
meetings with Bin Laden but later freed. Both Mehmood and Majeed‘s assets were frozen by the
U.S. Treasury Department on December 20, 2001, and both men were designated SDGTs.
Rabita Trust for the Rehabilitation of Stranded Pakistanis
The Rabita Trust, while ostensibly working in Pakistan, has its roots in Saudi Arabia. In
July 1988, Pakistani President Zia ul-Haq and Dr. Abdullah Omar Naseef, the then-Secretary-
General of the World League (MWL), established the Rabita Trust for the repatriation and
rehabilitation of stranded Pakistanis.27 The Muslim World League (MWL) is an organization
based in Mecca, Saudi Arabia, and is funded by wealthy Saudis.28 Naseef also served as —one of
the vice-presidents of Rabita Trust“29 and is currently the chairman of the foundation.30
Effectively, the Rabita Trust is a subsidiary of the Muslim World League, and therefore an
offshoot of a Saudi organization.
Operating under the guise of a charity, the Rabita Trust instead served to promote
terrorism. According to a press release issued by the Department of the Treasury on October 12,
The Secretary-General of the Rabita Trust Wa‘el Hamza Jalaidan, one of the
founders of Al-Qaeda along with Osama bin Laden. Wa‘el Julaidan is the
logistics chief of Bin Laden‘s organization and fought on Bin Laden‘s side in
Rabita Trust was designated a SDGT on October 12, 2001, by President Bush‘s Executive Order
freezing the assets of terrorists and terrorist groups.
3. Qatar Charitable Society
Another charity engaged in the financing of al-Qaeda and other organizational terrorist
operations is the Qatar Charitable Society (QCS). According to the Qatar Charity Society‘s
website, its mission statement claims that:
QCS aims to offer relief and help to orphans, victims of war and disasters by
supporting them financially, socially and culturally up to the age of 18. QCS aids
Syed Ehsanul Haque. —The Stranded People Who Spent 29 Years in Captivity.“ Daily Arab News, Jeddah,
December 16, 2000
Bruce Zagaris. —U.S. and Other Countries Attack Against Additional List of Terrorist Supporters. International
Enforcement Law Reporter, Vol. 17, No. 12. December 2001.
—News from Bangladesh.“ http://bangladesh-web.com/news/jun/07/nv4n589.htm
Mutahir Kazmi. —Repatriation of Stranded Pakistanis to Launch in April One Thousand Housing Units Ready
to House 5000 People.“ Pakistan News Service. http://paknews.com/art1apl-3.html
widows to meet living expenses particularly those who lost all relatives and
According to a WHOIS lookup of the Qatar Charitable Society‘s website,
www.qsociety.org, Hashem Hussein is listed as both the Administrative and Billing Contact for
the site. He lists the email address —hashim@MMAA.GOV.QA,“ indicating that Hashem
Hussein works for the Qatari government. The MMAA is The Ministry of Municipal Affairs and
Agriculture, and its website can be reached at www.mmaa.gov.qa.
In trial proceedings surrounding the prosecution of individuals associated with the
conspiracy to bomb the U.S. Embassies in Kenya and Tanzania in 1998, another charity was
mentioned as serving as a supporting organization for al-Qaeda. This organization was the Qatar
Charitable Society. Jamal Ahmed Al-Fadl, a former member of al-Qaeda and a state witness at
the trial, worked with the Qatar Charitable Society in 1993.32 When asked about his relationship
with the group, Al-Fadl replied:
The guy, he runs a group, he is one of our membership, one of the al Qaeda group
membership, and also he is Islamic National Front membership, and he was in
Afghanistan. So he helped our people for the travel, documents, and also if some
money come from the Gulf area to the organization, he gives the group some money
from that money.33
This leader is further identified as Dr. Abdullah Mohamed Yusef, a veterinarian whose role was
elaborated more by Al-Fadl when he stated, —He helped the jihad Eritrea group, and also he give
$20,000 for one of the attack outside of Sudan.“34
In his second day on the witness stand, Al-Fadl discusses a meeting in 1994 with the
Qatar Charitable Organization referred to here as Jam Qatar Heira:
Q. Where was it?
A. In Jam Qatar Heira. It's Qatar organization [Society].
Q. Is that the same organization you described yesterday or a different one?
A. Yes, same one.
Q. Is that the Qatar Charitable Organization [Society]?
Q. What happened at that meeting?
United States of America v. Usama Bin Laden, el al. Day 2, February 6, 2001. Page 329.
United States of America v. Usama Bin Laden, el al. Day 2, February 6, 2001. Page 330
A. Dr. Munim al Khabir, he say some members in Islamic National Front, they believe
they did their best to bring Saddiq al Mahdi to make relationship with him to start
something, unite all the groups of Sudan to run the government, but Saddiq al Mahdi, he
don't like that because we change the government during his time, and he say some people
say if we kill him is better for Sudan, because Saddiq al Mahdi got relationship with other
countries, and any time we find a chance, he told them, and he make them mad against the
Islamic National Front in Sudan.35
The Qatar Charitable Society provides another example of how the al-Qaeda terrorist
organization has been able to infiltrate charitable organizations in order to provide funding for its
terrorist ventures. The truth remains that this pattern of charitable organizations funding
terrorism is a common denominator among terrorist groups.
b. Hamas Use of Charities
1. Holy Land Foundation for Relief and Development
On December 4, 2001, President Bush, froze the assets of the Holy Land Foundation for
Relief and Development (HLFRD). While stating that HLFRD‘s money was used to support the
Hamas terrorist organization, President Bush further stated, —Those who do business with terror
will do no business with the United States or anywhere else the United States can reach.“36
HLFRD provides one of the best examples of how federal law enforcement could track the pro-
terrorist activities of an organization while being unable to cease such operations.
HLFRD, from its incorporation in 1989 until the freezing of its assets in 2001, collected
donations in the United States under the guise of a humanitarian and charitable organization.
These funds would be wired to Hamas charitable conduits within the West Bank and Gaza Strip
which would then transfer these funds to varying Hamas efforts, including, but not limited to,
suicide bombings and other terrorist exploits. As a 2001 FBI report states, —a significant portion
of the funds raised by the [HLFRD] are clearly being used by the HAMAS organization.“
Hamas is currently a designated foreign terrorist organization pursuant to powers bestowed upon
the United States Department of State under the Antiterrorism and Effective Death Penalty Act
According to the FBI‘s 2001 report, —In 1993 and 1994, the FBI monitored meetings of
identified HAMAS leaders and senior representatives from the [HLFRD]. During these
meetings, discussions were held regarding the need for HAMAS fund-raising in the United
States, as well as the primary role of the [HLFRD] to serve this function.“ Meetings under
surveillance by federal law enforcement included a 1993 meeting in Philadelphia of high-ranking
members of Hamas, HLFRD, and another related organization œ the Islamic Association for
Palestine (IAP). According to the FBI, —It was decided that most or almost all of the funds
collected in the future should be directed to enhance the Islamic Resistance Movement [Hamas]
and to weaken the self-rule government [in Israel].“
United States of America v. Usama Bin Laden, el al. Day 3, February 7, 2001. Page 380.
Remarks of President George W. Bush, December 4, 2001.
This meeting stressed that the capabilities for fund-raising within the United States were
amplified by the —democratic environment in the United States.“ As the FBI states in its report
regarding this meeting, —The participants decided that for fund-raising purposes, the United
States theater was very valuable to them. They stated they could not afford to lose it.“ In other
words, as with other terrorist organizations raising funds within the United States, the ability to
exploit the freedoms here was of paramount importance and relevance. Thus, Hamas terrorist
operations could flourish through the assistance of monies received from the United States vis-à-
vis HLFRD. Even so, HLFRD was not the only charitable organization utilized by Hamas for
funding purposes during the past two decades.
2. Al-Aqsa Educational Fund
In 1993, Abdelhalim al-Ashqar incorporated the al-Aqsa Educational Fund (AAEF), at
the University of Mississippi, ostensibly to raise money for charities located in Gaza and the
West Bank. Al-Aqsa Educational Fund published an advertisement in the October 15, 1993
edition of the Islamic Association for Palestine/Hamas Arabic-language publication al-Zaytouna
that shows the primary purpose of the fund:
[AAEF is a] non-profit charitable association acting for the education of the Palestinian with the
° Support association for education
° Support the deportees in Marj al-Zuhour [in 1992, Israel deported more than 400
members of both Hamas and the Palestinian Islamic Jihad to Lebanon where they remained
in Marj al-Zuhour until international pressure forced Israel to accept these deportees bank
° Provide the opportunity of education for our people’s children
° Especially the children of the martyrs, the prisoners and the fosters
° And for students who can’t complete their studies because of financial reasons
AAEF is described as a Hamas-front in the FBI‘s 2001 report on the Holy Land
Foundation (cited above). According to the FBI, in early 1994, the AAEF was in competition
with HLFRD for Hamas fund-raising in the US.37 The conflict arose from Hamas Political
Bureau head Mousa Abu Marzook‘s decision to choose HLFRD over the AAEF as Hamas‘
primary fund-raising entity in the US.38
Abdelhalim al-Ashqar is a Palestinian who currently resides in Alexandria, Virginia, and
has lived in the United States since 1989. The FBI Memorandum on HLFRD states that in 1992
the government of Israel notified the FBI that al-Ashqar was —a U.S.-based Hamas activist who
was involved in transferring funds from the United States to Hamas in the West Bank and
Gaza.“39 Al-Ashqar was the organizer of the above-referenced Philadelphia meeting in 1993 in
which high-ranking members of HLFRD and Hamas were involved.
—Holy Land Foundation for Relief and Development International Emergency Economic Powers Act.“ Action
Memorandum. Federal Bureau of Investigation. November 5, 2001.
After being called before a grand jury investigation exploring the activities of Hamas
within the U.S., al-Ashqar refused to cooperate, and, on February 23, 1998, Judge Denise L.
Cote found al-Ashqar in contempt, for which he was jailed. Al-Ashqar was subsequently
released from prison, after it became clear that he would not change his mind about testifying.
The April 2, 1998, edition of the Arabic-language newspaper al-Risala states that, at the time he
was called before the grand jury to testify, al-Ashqar was a Research Associate at the United
Association for Studies and Research (UASR), which was founded in 1989 by the head of the
Hamas Political Bureau, Mousa Abu Marzook. Prior to moving to the United States, al-Ashqar
had served as head of Public Relations at the Islamic University in Gaza for a period of about
eight years. According to documents submitted in the Abu Marzook extradition proceedings,
whose trial precipitated the grand jury investigation, this university was founded by, among
others, Abu Marzook and Hamas founder Sheikh Ahmed Yassin (about whom UASR has written
The use of charitable organizations as fund-raising conduits for al-Qaeda and Hamas
show how this tactic has been accepted by multiple terrorist organizations as a means of
financing. Similar examples can be shown through charitable conduits set up by other such
terrorist organizations as the Palestinian Islamic Jihad. Another means of fund-raising for
terrorist organizations is through the use of corporate fronts through which terrorist activities are
shielded or where corporate proceeds are used to support the various terrorist ventures.
II. Corporations/For-Profit Entities
Whereas charities and other similar non-profit entities provide excellent cover for
terrorists, the usage of for-profit corporations and entities for funneling money to international
terrorists has also been uncovered as a part of the support infrastructure. These for-profit bodies
can alter their balance sheets and financial statements in order to hide the fact that profits from
various commercial enterprises (including real estate deals, Internet ventures, and other
seemingly innocuous business transactions) were used to finance terrorism worldwide. With this
accounting mechanism in place, a corporate model allows terrorists to transfer money between
branches around the world with little public or government scrutiny.
a. Al-Qaeda‘s Use of Corporate Enterprises
1. Darkazanli Import-Export Company
Darkazanli Import-Export Company (Darkazanli)40 was the first private business to have
its assets frozen by President Bush due to suspected links with the September 11 attacks. The
White House executive order published on September 25, 2001, describes this Hamburg-based
company as a —front group“ for al-Qaeda41 and its CEO, the Syrian-born businessman Mamoun
Darkazanli, as one of Bin Laden‘s financial lieutenants.42 In fact, Darkazanli offers a strategic
paradigm for the manner in which a small, legitimate business with convenient European
According to the Dun & Bradstreet, Inc. WorldBase, Darkazanli Import-Export Co. was founded in 1993 and
specialized in the sale of whole electrical equipment such as electrical appliances, TVs, radios, etc.
The Times (London). November 2, 2001. —America Denies its ”Hospitality‘ to Supporters of Terrorism.“
Agence France Press. November 2, 2001. —Updated List of People, Groups Targeted in Asset Freeze.“
locations and inconspicuous business transactions, can be misused to launder money, purchase
sensitive technical equipment, and facilitate the establishment œ both in Europe and elsewhere œ
of business —front“ groups for al-Qaeda.
Darkazanli has strong U.S. connections. The company‘s name surfaced during a 1997
FBI raid on the home of former Bin Laden personal secretary, U.S. citizen Wadih El-Hage.43 The
raid produced a business card for —Anhar Trading Co.,“ listing El Hage as its director and giving
two addresses for the company‘s location. The U.S. address coincides with El-Hage‘s home
address in Arlington, Texas; whereas, the address in Germany œ —Uhlenhorster Weg 34, 2000
Hamburg 76“44 œ matches exactly the location and phone and fax numbers for Mamoun
Darkazanli and Darkazanli Import-Export Company. In fact, during a 1993 business trip to
Cyprus to purchase a ship for Bin Laden, Wadih El-Hage asked that all related business
documents be sent to his business address in Germany, that is, the business address of
Darkazanli.45 Therefore, al-Qaeda used Darkazanli both to facilitate and to legitimate its
terrorism activities by camouflaging its existence and business location behind an active —front“
Darkazanli is also involved with a second Bin Laden financial operative, the Sudanese
engineer Mamdouh Mahmud Salim.46 In Sudan, Salim once directed Wadi Aqiq, an umbrella
company for Bin Laden, and was engaged in al-Qaeda military training.47 In the period between
1995 and 1998, Salim made frequent trips to Germany with the purpose of obtaining electronic
equipment for Bin Laden‘s network48. Washington officials also suspect that, during those trips,
Salim tried to procure enriched uranium for al-Qaeda.49 On both occasions, Mamoun Darkazanli
and Darkazanli Import-Export Company provided cover, business collaboration and facilitated
communication for Bin Laden‘s financial chief and his transactions. For instance, in 1995,
Mamoun Darkazanli co-signed with Mamdouh Salim a joint Deutsche Bank business account,
over which, when Salim was away from Germany, Mamoun Darkazanli had the power of
attorney.50 Mamoun Darkazanli acted as Salim‘s host, translator, and business partner in
Germany.51 In addition, the Darkazanli company‘s specialty in the import-export of electronic
appliances, was a suitable cover for procuring technical equipment for al-Qaeda.
Wadih El Hage ran a number of Bin Laden‘s companies, and is currently serving a life sentence in U.S. prison for
his role in the planning and execution of the 1998 embassy bombings in Kenya and Tanzania.
See exhibit of Wadih El-Hage‘s business card.
The New York Times. December 27, 2001. —A Tramp Freighter‘s Money Trail to Bin Laden.“
Mamdouh Mahmud Salim is currently the highest-ranking Bin Laden official in U.S. custody, awaiting trial on
terrorism conspiracy charges.
CNN. October 16, 2001. —Embassy Bombings Trial Revealed Bin Laden Links.“
The New York Times. November 18, 2001. —Retracing a Trail to Sept. 11 Plot.“
FBIS translation. Paris Al-Watan Al-'Arabi. November 16, 1998. —Afghanistan: Report Links Bin-Ladin, Nuclear
The New York Times. October 7, 2001. —Syrian in Hamburg Linked to Second Bin Laden Aide.“
2. Barakaat Telecommunications / InterWAVE
When corporations operating on behalf of al-Qaeda (or other terrorist organizations)
desire to infiltrate a certain market or country, they often search for unwitting corporate
accomplices within the particular market whose activities are respected and established. This
was the situation that existed between Barakaat Telecommunications and the U.S.-based
After the September 11 attacks, the U.S. government froze the assets of the huge Al
Barakaat conglomerate on November 7, 2001, and designated Al Barakaat and its subsidiaries as
Specially Designated Global Terrorist Entities (SDGT). A prominent subsidiary of Al Barakaat
is Barakaat Telecommunications, renowned for its huge telecommunications market share in
Somalia. Working throughout Somalia, the network of telecommunications offices was used to
foster banking activity.52
By controlling communications throughout Somalia, Barakaat could ensure that terrorists
received a means to communicate with each other, via the Internet or over secure telephones.
Furthermore, since Somalia lacks any official currency, Barakaat Telecommunications served to
disperse funds around the world œ usually through banks in the Gulf States. According to a
United States Institute of Peace (USIP) report from October 1998, the banking division of
Barakaat Telecommunications handled about U.S. $500,000 a month in transfers.53
Early in 2001, Barakaat Telecommunications and InterWAVE, a California-based
company, formed a synergy whereby InterWAVE was to be —a turnkey supplier of GSM [Global
System for Mobile Telecommunications] network equipment and services to expand Barakaat‘s
existing GSM Network.“54 In a press release, InterWAVE and Barakaat Telecommunications
celebrated their partnership, with Al Barakaat Vice President and CTO of its Dubai operations
Abdullahi Hussein Kahie stating, —Since entering into a strategic relationship with InterWAVE
two years ago and deploying an initial network for 10 service areas, InterWAVE has
demonstrated that they not only have the robust product necessary for the task, but their product
evolution is designed to get a greater number of networks up and running under capital
expenditure budget restraints…. InterWAVE‘s project management and support capabilities
have served Barakaat well and under the new political climate, we expect both ourselves and
InterWAVE to benefit greatly from an exponential growth in business.“55
The fact that Barakaat, a business working for al-Qaeda, could embark upon a business
relationship with an American company without any governmental agency, let alone the
corporation, knowing is testimony enough to the duplicity of terrorists. In this case, terrorists
themselves were effectively working within the United States, earning money, and spending that
money directly on the September 11 attacks. In terms of terrorist financing, a more frightening
Alex Bellos. —SOMALI BUSINESS ECHOES THE BOOM OF RIVAL GUNFIRE.“ The Guardian, London.
June 20, 1997
—Removing Barricades in Somalia.“ http://www.usip.org/pubs/pworks/pwks24/chap2_24.html
—BARAKAAT TELECOMMUNICATIONS SELECTS INTERWAVE FOR NETWORK EXPANSION IN
SOMALIA.“ Press Release. http://www.iwv.com/nt/press/barakaat.html, February 27, 2001
scenario can hardly be imagined. Yet, another equally frightening scenario exists where this
corporate example replicates itself under the onus of other terrorist organizations.
b. Hamas Utilization of Corporate Funding
1. InfoCom Corporation
On September 5, 2001, agents from the Joint Terrorism Task Force operating out of
Dallas, Texas, instituted a search warrant against InfoCom Corporation, an Internet service
provider in Richardson, Texas, for its ties to the Hamas terrorist organization. The Office of
Foreign Assets Control (OFAC) notified InfoCom that two of its bank accounts, totaling
$70,000, had been frozen due to a lump-sum investment of $250,000 provided to InfoCom in
1993 by Nadia Elashi Marzook, the wife of Hamas leader Mousa Abu Marzook who is named by
OFAC as a specially-designated terrorist for his leadership role in the Hamas terrorist
organization.56 As a by-product of the search instituted against InfoCom, the Bureau of Export
Administration had suspended InfoCom‘s export privileges based on suspicions that InfoCom
had violated U.S. export control laws by making shipments to Libya and Iran, two states listed as
state sponsors of terrorism to which any export shipments are prohibited under U.S. law.57
At the time of the search, subpoenas were served on two of InfoCom‘s clients, the
Islamic Association for Palestine (IAP) and the Holy Land Foundation for Relief and
Development (HLFRD). As previously discussed, HLFRD‘s assets were frozen by executive
order on December 4, 2001, as a primary fund-raising entity for the Hamas terrorist organization.
Furthermore, an INS document issued in August 2001 referred to IAP as —an organization which
advocates the spreading of propaganda supporting HAMAS.“58
2. Quranic Literacy Institute
In June 1998, the United States Government instituted a civil forfeiture action against the
assets of the Quranic Literacy Institute (QLI), a corporation based in Chicago, Illinois, and
Mohammad Salah (who will be discussed later). The basis for this civil forfeiture, an action
typically reserved for drug-smuggling and dealing operations, arose as a result of a federal
investigation of transfers of money by both QLI and Salah in which the FBI concluded —there is
probable cause to believe that some of these transfers and transmissions have been of money
intended for use in support of domestic and international terrorist activities…. [T]he illegal
transfers have supported specific terrorist activities involving the extortion, kidnaping [sic] and
murder of the citizens and government of the State of Israel….“59 The focus here is the use of
QLI as a corporate entity to launder funds for the Hamas terrorist organization. The
Steve McGonigle, —Local Firm‘s Accounts Frozen; Investment by wife of Hamas leader is behind decision,
lawyer says,“ Dallas Morning News, September 26, 2001.
Steve McGonigle, —Firm‘s export license lifted; Company investigated by terrorism task force predicts
exoneration,“ Dallas Morning News, September 8, 2001.
In the matter of Hasan Faisal Yousef Sabri, Notice of Revocation of petition for Amerasian, Widow, or Special
Immigrant (Form I-360), Attachment.
United States v. One 1997 E135 Ford Van, United States District Court for the Northern District of Illinois œ
Eastern Division, Case No. 98C 3548, Affidavit of FBI Special Agent Robert Wright, pp. 1-2.
interrelationship between QLI and Salah, who was arrested and served five years in prison in
Israel for providing funds and instructions to Hamas military leaders in the West Bank and Gaza
Strip, provides another example of how terrorist organizations have succeeded in providing
funding from within the United States.
Bank records show that QLI President, Ahmad Zaki Hammad, gave Salah three checks
for $6,000 each on three consecutive days in October, 1991. The checks were not drawn from
QLI bank accounts, but rather came from Hammad‘s personal account.
On June 18, 1991, bank records show Salah received $40,500 in the form of five separate
cashier‘s checks. The checks were obtained by Linda Abusharif, the sister of QLI treasurer
QLI‘s relationship with Salah helped him obtain a mortgage to purchase his house in
Bridgeview, Illinois. QLI vouched to the lending bank that Salah was an employee of the
organization, earning $36,000 a year. The FBI investigation found that Salah never was an
employee of QLI as he and the organization claimed.
FBI investigators found evidence of a land deal conducted by QLI with the backing of a
Saudi named Yassin Kadi whose assets have been frozen by President Bush since September 11,
2001, for his role in financing a number of al-Qaeda ventures. The FBI affidavit filed in
conjunction with the civil forfeiture action stated that the intent of the deal was to raise money
for Salah and others to distribute to Hamas. In short, the deal involved QLI using Kadi‘s money
($820,000 wired from Switzerland) to purchase a tract of land in Illinois with a company called
—Golden Marble,“ run by Dr. Tamer Al-Rafai, a doctor and businessman. The idea apparently
was to generate income by renting out the property, then sell it when a large infusion of cash was
Though this case continues to be litigated in Illinois, it shows how federal law
enforcement authorities have observed other means of fund-raising for terrorist causes.
c. Hizballah Money Laundering
Terrorism fund-raising and support has also been propagated under standard money
laundering principles. Though this money laundering was not conducted under the auspices of
corporate activities, the Lebanese Hizballah has managed to find support within the United States
from individuals who are willing to supply to them technologically-advanced equipment that
they could not otherwise procure. Multiple cases are currently being prosecuted in the United
States; however, a singular snapshot is provided here to show how these activities were financed.
On July 21, 2000, agents from the Federal Bureau of Investigation (FBI) in Charlotte,
North Carolina, arrested eleven individuals on charges of smuggling contraband cigarettes to
Michigan from North Carolina and money-laundering. In a superseding indictment filed in the
United States District Court for the Eastern District of North Carolina on March 28, 2001, four
individuals were charged with providing —material support or resources to a foreign terrorist
organization“ in violation of 18 U.S.C. § 2339B. Specifically the individuals were charged with
providing —currency, financial services, training, false documentation and identification,
communications equipment, explosives, and other physical assets to Hizballah, in order to
facilitate its violent attacks.“60 According to the indictment, the members of the cell planned to
acquire such items as night vision devices, global positioning systems, mine and metal detection
equipment, stun guns, nitrogen cutters, laser range finders, and camera equipment.61
The money-laundering scheme alleged by the Government was simple: the defendants
would buy large amounts of cigarettes in the State of North Carolina where the price of cigarettes
was extremely low. Then, they would transport these cigarettes to Michigan where the price of
cigarettes was significantly higher. The Government alleged that the proceeds of the sale of the
cigarettes in Michigan was used to finance the purchase of the above-mentioned items for the
Hizballah terrorist organization.
In addition to the funds raised from the cigarette sales, these individuals also engaged in
credit card fraud to facilitate their purchases. Five individuals were charged with obtaining a
false drivers license which was used to submit fraudulent credit card applications. One
individual used various aliases to obtain additional fraudulent credit cards. Said Mohamad Harb,
also one of these five individuals, bribed an employee of First Union National Bank to reactivate
a closed account of an individual who had left the U.S. to execute a check fraud scheme.
These examples illustrate how individuals have managed to exploit lax regulations
pertaining to the issuance of identification in order to engage in credit card fraud and money
laundering to finance and equip terrorist organizations abroad.
III. Couriers and Financial Institutions
In addition to the use of charities and for-profit corporate entities and ventures, terrorism
fund-raising has also incorporated the use of banking and other financial institutions in addition
to individual courier arrangements and the concept of hawala.
a. Al-Qaeda‘s Hawala transaction system
For terrorists, keeping their money trail as hidden as possible engenders a constant flow
of monetary resources. As such, financial transactions, one of the most heavily documented
activities in the United States, are a burden for terrorists trying to maintain anonymity. To
overcome this obstacle, al-Qaeda members and other terrorists have relied upon the Hawala
A Hawala transaction involves the paperless movement of money, whereby one
individual sends money to a target individual through a Hawala dealer. The Hawala dealer
communicates with another Hawala dealer near the target individual and has that dealer give the
money to the target individual. In the case of a Hawala, money is not sent or wired. Therefore,
United States v. Mohamad Youssef Hammoud et al., No. 00 CR 147 (W.D. N.C. filed July 20, 2000, amended
March 28, 2001) Superseding Bill of Indictment, ¶ 3.
United States v. Hammoud, W.D. N.C., No. 00CR147, supra. at n. 4, Superseding Bill of Indictment (filed March
28, 2001), at 42-43.
records of the transaction are kept to a minimum, and, if records are kept, they are often unclear
since there is no standard for record-keeping of these transactions. More importantly, these
transactions can occur at any time of the day or night, providing for the rapid transfer of money.
All of these attributes make Hawala banking an asset to terrorists wishing to transfer money to
Al Barakaat, which as described earlier had its assets frozen and was designated a SDGT
by the U.S. government, functioned as a Hawala, based out of Dubai, United Arab Emirates. Al
Barakaat had branches all over the world in 40 countries, including multiple offices in the United
States. The Al Barakaat conglomerate extended to over 187 offices around the world, with 60 of
those being located in Somalia.62 Al Barakaat was run by Ahmed Nur Ali Jim‘Ale, reputed to
have extensive ties to Osama Bin Laden by the U.S. government.
Al Barakaat‘s extensive network facilitated the clandestine transfer of money with ease
and rapidity. Such a tangled network creates huge obstacles in following the money flow
between terrorists and the speed at which the money travels makes finding where the terrorists‘
finances are at any given moment a Herculean task.
b. Bank al-Taqwa
According to President Bush, al-Taqwa is —an association of offshore banks and financial
management firms that have helped al-Qaeda shift money around the world.“ Al-Taqwa‘s
connections to al-Qaeda led the Bush administration to freeze al-Taqwa‘s assets on November 7,
2001. During this announcement, President Bush also stated that al-Taqwa skims money from
every transaction for the benefit of terrorist organizations and enables the proceeds of crime in
one country to be transferred to pay for terrorist acts in another.63
Al-Taqwa was founded by the Muslim Brotherhood in 1988 in the Bahamas and later in
1991 in Algeria, as the beginning of —establishing a world bank for fundamentalists“ aimed to
compete with Western financial institutions.64 Al-Taqwa reportedly has other branches in
Liechtenstein, Italy, Malta, and Panama with its headquarters in Switzerland. As a world bank
for fundamentalists, al-Taqwa was open to money laundering with a number of terrorist
organizations, most notably al-Qaeda and, in the past, Hamas.
Al-Taqwa enabled al-Qaeda‘s financial network to obscure its paper trail by transferring
money from one al-Taqwa branch to another. French Intelligence officials claim that by 1999,
the bank was channeling funds for Osama Bin Laden.65 A Swiss investigation that started in
2000 revealed that al-Taqwa transferred funds for Bin Laden from Kuwait and the United Arab
Emirates to al-Taqwa‘s affiliates in Malta and then on to Switzerland and the Bahamas.66 This
deceptive method of money laundering allows the source of al-Qaeda funds an additional layer
—Shutting Down the Terrorist Financial Network.“ U.S. Treasury Department Fact Sheet. November 7, 2001.
Bush, George W. President of the United States. "George W. Bush Delivers Remarks at the Treasury
Department's Financial Crimes Enforcement Network (FINCEN)." FDCH Political Transcripts. November 7, 2001.
Bodansky, Yossef. —Iran‘s Pincer Movement Gives it a Strong Say in the Gulf and Red Sea.“ Defense & Foreign
Affairs‘ Strategic Policy. March, 1992.
—Terror Cash Probe.“ The Scotsman Publications. September 17, 2001.
—Money Laundering Probe to Look at Possible Bin Laden Link.“ Agence France Presse. September 23, 2001.
of secrecy. In 2001, the Italian branch of al-Taqwa also came under investigation by authorities
as a channeling house for Bin Laden‘s funds.67
One reason for al-Taqwa‘s success in laundering terrorist money is its organization as an
anomalous network of loosely connected financial institutions. The Swiss branch of Al-Taqwa
Management changed its name in February 2001 to —Nada Management Organization,“ on the
advice of Swiss banking authorities.68 Through this name change, the Swiss branch avoided any
confusion with its parent group, —Taqwa,“ which is located in Panama.69 This allowed al-Taqwa
to further obscure the connections between its branches. In some countries, al-Taqwa has
exploited organizational structure loopholes to avoid money-laundering crimes. In Switzerland,
the Swiss Federal Banking Commission certified that the al-Taqwa headquarters in Geneva is
neither a bank nor a financial intermediary and, as such, is not subject to the country‘s money
laundering control regulations.70
Not surprisingly, al-Taqwa‘s support of terrorism goes beyond financial transactions.
Ahmed Idris Nasreddin, a founder and director of al-Taqwa, personally financed al-Qaeda by
utilizing the tax-exempt advantages of a charity. Nasreddin financially supported the Islamic
Cultural Center of Milan,71 which the U.S. Treasury press release coinciding with President
Bush‘s Executive Order freezing terrorists‘ assets on September 24, 2001, described as —the main
al-Qaeda station house in Europe“ that —used to facilitate the movement of weapons, men and
money across the world.“ P.F. Barchi, Nasreddin‘s lawyer, stated that Nasreddin made —charity“
donations to the Islamic Cultural Center of Milan that paid for rent, electricity, heating and
Dr. Yusuf Abdullah Al-Qaradawi is on al-Taqwa‘s Shari‘ah Board and one of Taqwa‘s
largest shareholders as of December 31, 1999, with over 5,000 shares. Al-Qaradawi resides in
Qatar and is one of the most popular clerics in the Muslim Brotherhood movement. Statements
by him in the past and present indicate his affinity toward the terrorist activities of such groups
as Hamas, Islamic Jihad and others and his justification of these activities as integral components
of the Islamic way of life. In an interview that appeared in the September 1999 edition of the
Palestine Times with Qaradawi, he suggests that if one cannot actively participate in the armed
struggle, then he or she should provide financial support such that the Mujahideen can fight on
behalf of all Muslims.
Qaradawi blesses, —the martyrdom operations in which a given Muslim fighter turns
himself or herself into a human bomb that casts terror in the hearts of the enemy…. If we can‘t
carry out acts of Jihad ourselves, we at least should support and prop up the Mujahideen
financially and morally so that they will be steadfast until God‘s victory.“73
—Nerves on a Knife-edge.“ Sunday Times (London). September 23, 2001.
—Bank with Alleged Bin Laden Links Never Existed.“ Deutsche Presse-Agentur. September 20, 2001.
—Swiss Banking Officials: ”No Evidence‘ bin-Ladin Funds Handled by Taqwa Group.“ Paris AFP. September 19,
—Switzerland Confirms Role in US Anti-Terror Probe.“ BBC Worldwide Monitoring. September 26, 2001.
—Investigation Into US Terrorist Attacks Uncovers New Swiss Connections.“ Le Temps. November 22, 2001.
Hosenball, Mark. McGinn, Daniel. —Periscope.“ Newsweek. November 12, 2001.
—Interview Sheikh Yousuf al-Qaradawi: Hamas and the Islamic Jihad represent the glorious face of the Islamic
Umma.“ Palestine Times. September 1999.
Qaradawi has also called for an —electronic jihad“ and, just a few weeks before the
attacks on September 11, he published a fatwa on his website, qaradawi.net, in which he praised
suicide attacks, calling them —the highest form of jihad.“
c. Hamas‘ Al-Aqsa Bank, Beit al-Mal, and Joint Ventures with Citibank
The Al-Aqsa Bank and Beit al-Mal are both examples of terrorist organizations using
financial institutions to launder money, and of a funding front integrating a legitimate business
into its network. After $30 million disappeared from its accounts with the designated terrorist
group al-Taqwa Bank, the —world bank for fundamentalists,“ Hamas established Al-Aqsa Islamic
Bank in 1997.74
Mohammed Sarsour, a U.S. citizen and former Vice-President of Bir Zeit University, is
both Deputy General of Al-Aqsa Islamic Bank and General Manager of Beit al-Mal Holdings.75
Beit al-Mal Holdings is part owner of Al-Aqsa Islamic Bank, with a $4,000,000 capital
investment.76 Both are part owners of Sinokrot Global Group,77 founded by mutual board
member Mazen Sinokrot. Essentially, these three financial groups œ Beit al-Mal, Al-Aqsa, and
Sinokrot Global œ share founders, board members, and funds, and cooperatively act as a buffer
between Hamas and its donors.
However, due to their money laundering operations, Israel banned both Beit al-Mal‘s and
Al-Aqsa‘s operations.78 The United States, also, has frozen both companies‘ assets. President
Bush referred to banning the banks as —freezing the assets of Hamas.“79
In order to bypass Israeli restrictions and make its funds accessible to Hamas operatives
in Israel and the territories, Al-Aqsa embarked on joint projects with Citigroup, intertwining
itself with Citibank‘s Israel division.80 Soon, al-Aqsa and Citibank shared a single database for
Israel. Money deposited into Al-Aqsa accounts in Europe or other parts of the Middle East
became accessible from Israel through Citibank chapters.
When Citibank was opening an office in Tel Aviv in January 2001, Israeli authorities
formally questioned its ties to Al-Aqsa, prompting Citigroup to request advice from the U.S.
Treasury Department.81 Citigroup has not released any information on the Treasury
Department‘s response, but has since severed its ties to Al-Aqsa. Israeli counterterrorism
authorities estimate that over $1,000,000 has been deposited into al-Aqsa accounts for Hamas
—Iran‘s Pincer Movement Gives it a Strong Say in the Gulf and Red Sea.“ Defense & Foreign Affairs‘ Strategic
Policy. March, 1992.
The Palestinian Businessmen Association œ Jerusalem. Http://www.pba-
palestine.org/general/memers/members2.htm AND —Palestine: Ambitious Investors get a Rude Awakening.“ Global
Information Network. May 16, 1997
Al-Ayyam. July 28, 1999.
Sinokrot Global Group Affiliations & Memberships. Http://www.sinokrot.com/memberships.html. 2001.
—Court Asks State Why it Took $1 Million of HAMAS Cash.“ Ha‘aretz. September 15, 2000.
—Citibank Weighs Ending Ties with an Arab Bank.“ New York Times. January 24, 2001.
since its affiliation with Citibank.82 At least some of this money reached Hamas through
d. Hamas‘ Use of Couriers
Similar to the hawala banking system described above, the Hamas terrorist organization
has utilized a system of money couriers to transport funds from the United States to Hamas
military leaders in the West Bank and Gaza Strip. The most famous example of this type of
activity was the arrest in Israel of Mohammad Salah, a Chicago resident, for carrying funds from
Hamas leader Mousa Abu Marzook to Hamas military leaders in January 1993. Released from
Israeli prison in 1997, Salah returned to Chicago, and, in June 1998, the U.S. Government
instituted a civil forfeiture action against his assets based on his alleged involvement in money
laundering for terrorism. In the FBI affidavit supporting the civil forfeiture, FBI Special Agent
Robert Wright detailed cash transfers from Salah to Hamas military leaders that were offset by
complementary deposits by Hamas leader Marzook into Salah‘s U.S. bank account.
In addition to Salah, a Milwaukee family has also been implicated in carrying money
from the United States to Hamas leaders in Israel and the Occupied Territories. According to the
FBI report detailing the activities of the Holy Land Foundation for Relief and Development
(HLFRD), the following was written regarding the Sarsour family:
Jamil Sarsour confession: On October 23, 1998, Sarsour was arrested by the
[Government of Israel] for his involvement with the HAMAS terrorist
organization, specifically, for providing financial and other assistance to HAMAS
fugitive and military activist, Adel Awadallah. At the time of his arrest, Sarsour
was carrying $66,530.00, a personal telephone book and two American passports.
Sarsour was interviewed and provided information concerning his and his brother,
Salah‘s activities in support of HAMAS over the last several years.
During the course of his interview, Sarsour described his brother Salah Sarsour‘s
involvement with HAMAS and fund-raising activities by the [Holy Land
Foundation] … on behalf of HAMAS. Sarsour stated that … his brothers Salah
and Imad are involved in raising money in the name of the [Holy Land
Foundation] that is actually for HAMAS.
Sarsour's family name was mentioned in statements by Mohammed Salah after his arrest
and conviction in Israel. In his interrogation, Salah stated that the Sarsour family provided a
means for sending money to Hamas activists in the West Bank and Gaza. According to a
translation of his statements, Salah stated, —The Sarsour family is famous in America.“
Furthermore, Mohammad Sarsour, another member of the family, is the Deputy General of Al-
Aqsa Islamic Bank and General Manager of Beit al-Mal Holdings, two organizations mentioned
above whose assets have been ordered frozen by President Bush for their support of the Hamas
—Citibank Believed to Be Fund Conduit for Islamic group.“ Ha‘aretz. January 25, 2001.
IV. Terrorism Fundraising on the Internet
Another developing area where terrorists have found success in their fundraising efforts
is through the medium of the Internet. Contrary to the popular belief that terrorist organizations
are comprised of unsophisticated ruffians, the use of the Internet as a fundraising tool is
indicative of the savvy of these organizations and their technological capabilities.
a. Al-Rashid Trust
On September 24, 2001, President Bush signed an executive order freezing the assets of
the Pakistani-based Al-Rashid Trust. On October 31, 2001, Attorney General John Ashcroft
requested that the State Department designate Al-Rashid and several other groups named in the
executive order as —foreign terrorist organizations.“ Originally founded as a genuine charity in
the 1980s, Al-Rashid Trust was co-opted by radical Islamists to channel funds to the Afghan
mujahideen. When the Taliban took control of Afghanistan, Al-Rashid became the unofficial
donor-line to aid Mullah Mohammed Omar, the Taliban‘s leader. In 1999, one of Al-Rashid‘s
websites made an ominous prediction:
—With the imposition of American sanctions upon Afghanistan, an undeclared
cold was has begun between [the infidels] and Islam. In the near future
conditions will deteriorate further for that Islamic country because America in its
frustration will resort to further pressure-tactics and machinations, and if the
proud Muslims of Afghanistan continue their firm stand (as it is hoped they will)
then in all probability a fierce war will break out. In such conditions honour and
prudence demand that the Muslims make timely preparations.“84
Despite the harshness of its anti-American rhetoric, Al-Rashid has until recently been
able to openly advertise its presence on the Internet and solicit funds from website visitors. On
the former website of —Voice of the Taliban“ (http://www.dharb-i-mumin.com), guests were
greeted with a sleek pop-up appeal to donate to Al-Rashid. The appeal was directed particularly
at Taliban supporters in Great Britain and the U.S., listing two wire account numbers in Pakistan
œ one for dollars and one for pounds-sterling. Visitors were urged to —help your Afghan brothers
whole-heartedly.“ Like many of these radical fundraising messages, this website was being
hosted on a commercial Internet provider that is, in fact, based in the United States.
b. Global Jihad Fund (GJF)
Following the U.S. missile attacks against Afghanistan and the Sudan in August 1998, a
British Muslim named Mohammed Sohail announced on Internet public newsgroups that —the
global alliance of democracy, sodomy and international-law (unholy trinity) has attacked the
bases of Sheikh Mujahid Osama bin Laden… we Muslims must support the Sheikh against the
crusader-zionist world government (new world whoreder).“ Sohail finished his message by
quoting the Prophet Muhammed: —Perform jihad against the disbelievers, with your wealth,
yourselves and your tongues.“
After being confronted by reporters for the British Sunday Telegraph about his
statements, Sohail admitted being connected with a London-based organization known as the
—Global Jihad Fund.“ He explained: —I work as a volunteer helping with things such as
fundraising and recruitment for organizations involved in Jihad.“ He then went further and
affirmed, —I work for two people, really, Mr. Massari and Osama Bin Laden.“85
Visitors to the Global Jihad Fund (GJF) website86 are shown a monograph of several
flags, including those of the U.S., U.K., France, and Israel. Superimposed over this image is an
Arabic phrase, commanding faithful Muslims to —kill them all until there will be no more
struggle and the word of Allah will be the only one.“ The site continues by explaining, —the
main aim… of Global Jihad Fund is to facilitate the Growth of various Jihad Movements around
the World by supplying them with sufficient Funds to purchase Weapons and train their
Individuals.“ In August 1998, Mohammed Sohail confirmed in another Internet newsgroup
posting that —GJF supports Sheikh Mujahid Osama bin Laden.“
On the GJF website, there are a number of articles dealing with the subject of jihad.
Among the most shocking is an alleged interview with a Pakistani child who claimed to have
been to Afghanistan on several occasions —to wage jihad.“ In addition to expressing his
enjoyment at helping to kill the enemy, the young man explained that his future goal was to give
the United States —a good beating.“
The Global Jihad Fund maintained a relatively sophisticated fundraising network in
London for the purpose of aiding international Islamic —holy warriors“ in such places as Bosnia,
Afghanistan, Kashmir, Kosovo, and Chechnya. The group encouraged Muslims outside of
London to —Start a Jihad Support Network in your city… don't be afraid of [the tyranny of the
infidels].“ Its website still offers —jihad military training“ in several undisclosed locations. The
Sunday Telegraph investigation also revealed that, as a result, —dozens of volunteers are being
drilled in the use of guns and explosives,“ allegedly —to prepare them for the military wing of [al-
Qaeda].“87 When e-mailed in early 2000, the coordinators of the military training confirmed
that, indeed, they were recruiting international volunteers, including from the United States.
In fact, even U.S.-based Islamic radicals have established websites to support the jihadist
network of Osama Bin Laden. One Muslim-American claiming to be from Las Cruces, New
Mexico established —The Road to Jihad“ website.88 For almost two years prior to the events of
September 11, the introductory page to the website featured a large graphic of the New York city
skyline, with the American and Israeli flags burning above it. The site went on to offer audio
and video of Osama Bin Laden and other famous Arab-Afghans, bank account numbers for
donations to the Taliban and Laskhar-e-Taiba, and pages of practical and ideological advice for
budding jihadists. On August 22, 2001, the author of jihadroad.com wrote in an e-mail that he
Hastings, Chris and Jessica Berry. —Muslim militia training in Britain.“ The Ottawa Citizen. November 7, 1999.
Hastings, Chris and Jessica Berry. —Muslim militia training in Britain.“ The Ottawa Citizen. November 7, 1999.
http://www.jihadroad.com, http://www.jihadpath.com, http://members.nbci.com/_XMCM/jihadroad/index.html
had just returned from Afghanistan where he had sought —training and to perform jihad.“ He
reported that the Taliban were stockpiling large numbers of —brand new weapons (heavey[sic],
med, and light) and be used only in the jihad to open palestine.“ When asked about Osama Bin
Laden, he explained:
—I saw 100s of youth getting harsh training in remote camps all have one in mind to open
land [and] liberate palestine… Shaikh osama is the most humble kind sincere faithful simple
hundsom[sic] person u can ever meet… I advise u to migrate there and join the state.“89
Though —The Road to Jihad“ is no longer online, there is no indication that any official
action has been taken against its former Webmaster.
c. Hamas‘ 101 Days Campaign
In the 101 Days charity campaign, the terrorist movement Hamas has managed to
combine both the requirements of political propaganda and the endeavors of terrorism financing.
Launched and advertised through the official Hamas website (http://www.palestine-info.net), 101
Days unites the resources and efforts of a number of legal and illegal Islamic charities. The
purported goal is to assist —our Palestinian brothers and sisters in support of their steadfastness“
against —the illegitimate occupation of Palestine.“ Yet, this charitable fundraising campaign is an
excellent case-in-point of how terrorist movements use the internet and modern technologies to
raise money and recruit supporters.
The 101 Days logo is featured by the Hamas official website in Arabic. If an Internet
viewer clicks on it, the logo transports him or her to the comprehensive 101 Days Campaign site,
run by the United Kingdom-based charity Interpal, or the Palestinian Relief and Development
Fund.90 According to both the Israeli government and FBI reports, Interpal belongs to the Hamas
organization. Following the September 11 attacks and the U.S.-launched war on terrorism, the
101 Days website was updated to reflect the new political developments. When an Internet
viewer decides to donate on-line and goes to the United States section of the 101 Days website,
the names of both the Holy Land Foundation for Relief and Development (HLFRD) and the
Global Relief Foundation (GRF) appear. Yet, these charities are not listed among the official
organizations participating in the fundraising effort. In December 2001, the Bush administration
froze the assets of both of these organizations. The Internet site for the 101 Days campaign thus
provides an ingenuous way to both unite the efforts of various charity organizations and to
dissemble their direct participation.
E-mail from jihad goto (email@example.com). August 22, 2001.
The listed website address is www.interpal.org/web/ donation.htm.
V. A Case Study: The Embassy Bombing
In a presage of the September 11 attacks, the 1998 U.S. Embassy bombings in Nairobi,
Kenya, and Dar Es Salaam, Tanzania, exemplified al-Qaeda‘s efficient and simultaneous use of
corporations, charities, and financial systems to cause mass destruction to both people and
property. In a multiyear project, al-Qaeda members created a profitable fishing company,
established a working charity and commandeered another, and disseminated funding to the
terrorists through a Hawala bank. Most of these organizations were fully operational, and all
remained undetected, while providing material support for the terrorists. For the terrorists, the
fishing company provided money to live on, the charities supplied weapons and explosives, and
the Hawala bank injected funding from al-Qaeda members outside the operation. In an ironic
harmony, the organizations aided the terrorists with all the support they needed until havoc
ensued on August 7, 1998, when two embassies were destroyed and 224 people were killed.
a. The use of corporations
1. Al-Qaeda fishing company
Another convicted conspirator in the embassy bombing attack, Mohammed Sadiq Odeh,
established a fishing business in Mombassa, Kenya. Though Odeh claims to be merely a
commercial entrepreneur, the facts speak otherwise. Kenyan fishing inspector Kibarua Mjitta, a
government witness in the recent Embassy Bombing trial in New York, testified that Odeh‘s
business activities were quite suspicious-- he typically unloaded his catch at night, after
inspectors had already gone home: —The department was missing information, statistics from Mr.
Odeh.“91 Odeh refused to hire any locals to help him, bringing in any necessary manpower
exclusively from the al-Qaeda cell in Nairobi.
In fact, Odeh was using his business enterprise as fronts for al-Qaeda activities and
means to provide the cash for terrorist operations. Odeh used the fishing company‘s boat to flee
Nairobi the night before the bombings. FBI Agent Abigail Perkins, testifying based on
interviews she had with Khalfan Khamis Mohamed, convicted and sentenced to life in jail for his
role in the bombing, described another purpose for which Odeh‘s fishing boat was utilized:
Q. And did Khalfan Khamis Mohamed indicate to you if the boat was used for
any purpose other than fishing?
A. He did.
Q. What was that?
A. He said it was also used for jihad.92
United States of America v. Usama Bin Laden et al. February 27, 2001. Page 1614.
United States of America v. Usama Bin Laden et al. March 19, 2001. Page 2812
FBI Agent John Michael Anticev, in an exchange with Odeh‘s attorney Anthony Ricco,
affirmed based on interviews he had with Odeh that Abu Hafs, the military commander of al-
Qaeda recently killed in Afghanistan, gave the boat to Odeh:
Q. First he told you that there was a fishing business.
Q. And the fishing business came from a boat that he got from Abu Hafs, right?
Q. And the boat was from Al Qaeda. Right?
Q. And he said that the boat provided income for other members of Al Qaeda
who were in the area.93
This independent business structure is a particularly troubling development because it
heralds the likelihood of terrorist cells operating independently from any foreign financial
benefactor, raising the lionshare of their assets from otherwise legitimate, non-descript
2. Anhar Trading and Ties to the United States
Osama Bin Laden‘s former personal secretary, Wadih El-Hage, was a key figure in the
1998 terrorist attack. Despite being scrutinized by U.S. intelligence, El-Hage used his American
passport to guarantee freedom of movement. He traveled across Africa and Europe to search for
foreign business partners to team up with al-Qaeda front companies based in Kenya, Sudan, and
elsewhere. He engaged in enterprises as diverse as leather, gemstones, and even ostriches,
channeling profits from these ventures through a variety of international financial institutions,
including several Cypriot branches of large U.S. banks. When FBI agents searched El-Hage‘s
home, they found business cards for one of El-Hage‘s dummy corporations, —Anhar Trading.“
The German address on the card was, in fact, the Hamburg home of key Bin Laden financier
United States of America v. Usama Bin Laden et al. February 28, 2001. Page 1709
b. The use of charities
1. Mercy International Relief Agency (MIRA)
Wadih El-Hage was active in another typical al-Qaeda front activity: religious charity
groups. The thin veneer of legitimacy associated with these charity groups was critical in
preventing detection of the planned terrorist operations. A religious charity to play a major role
in the terror attacks in East Africa was Mercy International. Al Qaeda operatives used the
offices of Mercy in Nairobi as a critical communications and planning point. Abdullah
Mohammed, an alleged Kenya embassy bomber, carried eight boxes of El-Hage's personal
effects to Mercy‘s office. The items, seized later by the FBI, included false documents, letters,
faxes, and passports.
Patrick Fitzgerald, Assistant U.S. Attorney General, referring to documents seized at Mercy
International‘s office, affirmed the charity‘s hidden role as a front for al-Qaeda:
The enterprise charged in the document is with using nongovernment
organizations as a front…It is an office where documents were seized. These
documents show that Mercy International, while it does have legitimate charitable
purpose, has other purposes that are contrary to that.94
Moreover, documents that were seized show clearly the charity‘s involvement in smuggling
weapons into Kenya, as Patrick Fitzgerald indicated:
Receipt dated July 24, 1998, and on the back it said getting weapons from
2. —Help Africa People“:
In Kenya, El-Hage registered —Help Africa People,“ a humanitarian group supposedly
aiding indigent Africans with money raised from the U.S. and Germany. In fact, —Help Africa
People“ did little more than provide jobs and a cover to shield El-Hage and other conspirators
from official scrutiny while they plotted to strike against America. Shockingly, registry papers
for Help Africa People contained the name Moataz al-Hallak, a U.S.-based Islamic cleric who
has already been linked to the purchase of a jet aircraft for use by Bin Laden. Though
questioned by law enforcement on several occasions, al-Hallak remains in Maryland free of any
c. Moving Money œ Dahab Shil
Dahab Shil, a Hawala bank that functions much like Al Barakaat, should have
forewarned us of the dangers that became all too apparent on September 11. Based in Somalia,
United States of America v. Usama Bin Laden et al. Mach 20, 2001. Page 2998
United States of America v. Usama Bin Laden et al. Mach 20, 2001. Page 2999
Dahab Shil has at least 87 branches worldwide, including offices in Canada, New Zealand,
Australia, with approximately 10 branches in the United States.
Dahab Shil‘s infrastructure provided unquestioning support for the al-Qaeda member,
Mohamed al-Owhali, who was eventually convicted in the bombing of the U.S. Embassies in
Africa. Four days after he drove the truck-bomb to the U.S. Embassy in Nairobi, al-Owhali was
transferred $1,000 from an al-Qaeda member in Yemen.
VI. Recommendations/Modification of Current System
As investigators and law enforcement personnel attempt to assess the infiltration of
terrorist groups and funding within mainstream America, there is a growing understanding that
terrorist funding has been distributed through seemingly —legitimate“ conduits. A new approach
must be taken in order to prevent future funding of such groups. One area that needs to be
examined is the IRS 990 Return of Organization Exempt from Income Tax form. These forms
do not provide or require enough information from groups requesting 501(c)(3), tax-exempt
status. There are certain groups that have made attempts to falsify their intentions in order to gain
such status, thus enabling them to function in a —legitimate“ manner and at times move money to
terrorist groups and affiliates in a seemingly lawful method. In order to better assess the validity
of their charitable pursuits, these forms must require more essential information from the
submitting organization in order to better determine activities and affiliations of the group, as
well as specific details of monetary distributions. Specific examples of indiscretions of such
groups will be cited in order to give a better understanding of the manipulation of tax-exempt
Necessary Modifications to 990 Forms
Tighter regulations need to be created in order to gain a better understanding of who the
board of directors of these organizations are and what other groups they are affiliated with. A
standard needs to be set–much like that in the 2001 US PATRIOT Act–where members of
board of directors are mandated to provide legal names with matching address, phone and social
security numbers, as well as other boards that they serve upon. These stricter recommendations
will help provide authorities with a greater understanding of the board members and their
affiliations with other groups. For example, Abdurahman Alamoudi, who has voiced his support
of the terrorist groups Hamas and Hizballah, serves on the Board of Directors of Success
Foundation, Inc., an offshoot of the International Islamic Relief Organization (IIRO), a Saudi-
based charity whose charities have been used to provide money for al-Qaeda and Hamas terrorist
activities. Upon further examination of the 2000 Success Foundation, Inc. annual IRS 990 form,
one would find that the group provided funding to Human Appeal International, an Islamic
charity based overseas. In a report submitted by the FBI on November 5, 2001, Human Appeal
International was described as being closely connected to Hamas. In addition, Human Appeal
received large amounts of funding from the HLFRD.:
—FBI investigation has revealed a close relationship among the HLFRDRD,
HAMAS and HAI. FBI investigation has determined that the HLFRDRD
provides significant funding to HAI, which benefits the HAMAS agenda.“
In that same year, Success Foundation also provided funding to Ismail Elbarassee, a key US-
based Hamas leader, for Inmate Services. Elbarrasse held a joint bank account with Hamas
Political Leader Musa Abu Marzook, prior to Marzook‘s deportation to Jordan in 1997, from
which money was transferred to Muhammad Salah in Chicago. According to the FBI report
released on November 5, —SDT Mohammad Salah stated that he was directed by Marzook to
receive funds from Elbarasse to be used for funding HAMAS military operations.“
Careful inspection of 990 forms will show that there has not been enough evaluation
regarding the groups that are said to receive funds from the charitable organization. There is not
enough emphasis on trying to determine how funds have been distributed and to whom. For
example: in the 1999 990 form for LIFE for Relief and Development, formerly known as
International Relief Association, Inc., the group offers vague descriptions of money allocated
from its $9,183,936 earnings. Under Part III, Statement of Program Service Accomplishments,
they offer vague explanations for money allocations. $443,538 was given for —Disaster relief,
food and shelter provided in Turkey and other Asian countries.“ $7,174,820, a majority of the
group‘s earnings, was spent under the description —Food, shelter and medical supplies were
distributed in Iraq and Kurdistan with the help of other NGOs.“ These are just two examples
from one particular group although there are many other organizations that could be used as
illustrations of this problem.
Immediately many questions come to mind when examining these descriptions: what
particular organizations and individuals received these grants? What was actually provided under
the auspices of —disaster relief, food, and shelter?“ What NGOs assisted in the distribution of
goods? What other countries received assistance? Is there a way to be sure that the funds actually
reached said groups? Are these groups considered legitimate organizations by their native lands?
In order to assess these issues, organizations need to prove that they are providing funds for
legitimate organizations and that these allocations are actually going to the designated recipients.